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RYAN v. C. I. R.

Nos. 81-2459, 81-2460.

680 F.2d 324 (1982)

Patrick James RYAN, Appellant, v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

Decided June 2, 1982.

Attorney(s) appearing for the Case

Gannet & Apfel, Newark, N. J. (Herbert M. Gannet (argued), Kenneth S. Apfel, Newark, N. J., on the brief), for appellant.

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, William S. Estabrook, Philip I. Brennan (argued), Attys., Tax Div., Dept. of Justice, Washington, D. C., for appellee.

Before GIBBONS and HUNTER, Circuit Judges and GERRY, District Judge.

OPINION OF THE COURT

GIBBONS, Circuit Judge:

Appellant Patrick James Ryan is an individual taxpayer who has filed his federal income tax returns based on a calendar year. On March 1, 1977, the Commissioner of Internal Revenue (hereinafter Commissioner) invoked 26 U.S.C. § 6851(a) which authorizes, under certain circumstances, a termination of an individual's taxable year. On April 11, 1977, the Commissioner made a termination assessment of $81,107.64...

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